data security and protection toolkit questions

The Data Security and Protection Toolkit is an online self-assessment tool that allows organisations to measure their performance against the National Data Guardian’s 10 security standards. Queries on specific IG requirements can be found towards the bottom of the page. Does this mean that I need to provide the manufacturer with the name of the patient? Can one person be the IG lead for more than one pharmacy? If a pharmacy has missed the 31st March deadline, we would recommend contacting your local NHS England team to discuss this. It could be a stand-alone leaflet or relevant content in existing practice leaflets could be adapted and expanded. Q. I currently maintain a comprehensive list of the hardware and software I own for insurance purposes. name, address, dob etc. They have undergone two phases of consultation led by the PSNC. Find out what’s happening in the wider NHS. If you have queries on this webpage or you require more information please contact it@psnc.org.uk. Community Pharmacist Consultation Service (CPCS), Smartcard Registration Authority contacts, Community Pharmacy Patient Questionnaire (CPPQ), Show/Hide all pages in Contract and IT section, Emergency and Business Continuity Planning, Communications across healthcare using IT, Technology, infrastructure, reducing burden & workflows, Relocations which do not result in significant change, NHS Identity Guidelines: NHS logo use by pharmacies, Association of Police Controlled Drugs Liaison Officers, NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013, clinical governance section of the website, Contractor Notice: Online Drug Tariff emails, PSNC and BMA issue statement on medicines supply, Free campaign material to support ‘We Are Undefeatable’, December meeting of the Community Pharmacy Brexit Forum. Q. For example, if the laptop connects to the pharmacy network and is used to access the internet, one risk is that if the anti-virus on the laptop isn’t updated regularly, the laptop could introduce viruses to the local network that could compromise the security of information held on other computers connected to the network. For example: “Requirement not applicable, this pharmacy does not use removable or portable computing equipment including CDs/DVDs and USB sticks.” The pharmacy should ensure that staff do not use mobile computing devices in their role. Therefore if the device contains no personal information, it would not be necessary under the NHS Information Governance requirements to record staff use and provide guidance on use of the device. This will allow you to integrate it with any other soures to calculate your response to the Staff Awareness questions in the Toolkit… A local NHS England team may investigate a pharmacy that has not completed an annual return via the Information Governance Toolkit to satisfy itself that the pharmacy is meeting the Terms of Service requirements. A. The concept behind having an information asset register is identifying all relevant hardware, software and information to ensure it can be appropriately protected. You may receive reminders. Compliance with ‘Confidentiality: the NHS Code of Practice’ and data protection legislation are key elements (this means all community pharmacies need to provide information governance assurances to the NHS on an annual basis. 'About the Data Security and Protection Toolkit' provides an overview of what the toolkit is, who should complete the toolkit, and why. What is the DSP toolkit? Yes, this is possible but the batch submission process should be followed – due to be available from around the end of January 2019. A. Do they not have access to this through the Toolkit? CQC Key Lines of Enquiry; Data protection law; the 10 Data Security Standards. Q. It allows organisations to measure themselves against the NDG’s (National Data Guardian) data security standards. Data security standards - big picture guides. The Data & Security Protection Toolkit, formerly Information Governance Toolkit, must be completed every year by all pharmacies and businesses who have access to NHS patient data and systems. It is important to make some comments to support your score, this could be by making some comments in the comments box or ticking the relevant evidence obtained boxes but it is not mandatory to complete the optional fields to record where each piece of evidence is located or to upload evidence such as policies and procedures. Toolkit completion: Overview: Five steps for completing the Data Security and Protection Toolkit 2019/20– this gives a step-by-step guide to completing the Toolkit and references other materials. Q. These guides take you through the definitions used in the standards, what the standards are asking of you, suggestions and examples of how this might be achieved, how this relates to common current practises, and useful resources. Therefore, as an interim measure, if following a risk assessment it is felt that continued reliance upon unencrypted data is necessary for the benefit of patients, the outcome of the risk assessment must be reported to the most senior person in the organisation, so that he/she is appropriately accountable for the decision to accept data vulnerability or to curtail working practices in the interests of data security.” Therefore encryption had not been mandatory to achieve Level 2 compliance with the NHS IG requirements as outlined in the older version 9 of the IG Toolkit (now replaced by DSPTK). Do I need to do this? ; … Q. I run a wholly mail order business. For many of the questions, I don’t have the specific physical security controls in place however I am in an area of low crime. Follow @PSNCNews Click on a heading below to reveal FAQs on that topic. What does “data processed outside of the UK” relate to? The Toolkit isn’t ‘locked’ at midnight on the 31st March therefore it may be technically possible to still make a submission after the deadline. A. Q. I have just discovered I have made a mistake in my submission. A. If the pharmacy does not use any mobile computing devices i.e. Find out more about cookies. In the terms of the contract which the NHS England Area team has negotiated with the waste contractor, provision should have been made to safeguard confidential information. A. Q. I use a laptop in the pharmacy for connecting to the internet for drug information but it does not hold any patient sensitive information. When can I next submit an assessment? !function(d,s,id){var js,fjs=d.getElementsByTagName(s)[0],p=/^http:/.test(d.location)? Once I’ve registered for the IG Toolkit, how do I update my registered email address or other information? A. As part of requirements, you need to consider if information about patients is being transferred outside of the UK (e.g. A. Once IG policies and procedures are in place, pharmacy contractors should review these annually to ensure they remain relevant and appropriate, for example to ensure they continue to be in line with law in this area.   The 'Data Security Meta Standards' document gives the bigger picture of where the standards fit in. Mapping and Risk Assessing Information Flows. Q. A. Yes. A. Yes. Data protection legislation requires organisations to notify the Information Commissioner’s Office (ICO) if they are processing personal data – all pharmacies process personal data. Q. Both are linked to the same premises. Local administrators will have access to a report detailing the outcomes of the survey to facilitate IG Toolkit … Q. A data breach may trigger the need to review procedures during the year, for example to ensure they take into consideration lessons learned to prevent future breaches. The guidance is designed to be used by DSPT independent assessment providers, including internal auditors, when assessing DSPT submissions. The NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013 require that contractors have an “acceptable” information governance programme – if it is considered acceptable by NHS England and includes an information governance programme which provides for compliance with approved procedures for information management and security. No. Can a self-employed locum pharmacist be the IG lead for a pharmacy? 7. Encryption is referred to in relation to the NHS IG requirement on mobile computing. These guides for social care take you through the definitions used in the standards, what the standards are asking of you, suggestions and examples of how this might be achieved, how this relates to common current practises, and useful resources. This includes things like putting in place appropriate policies and procedures, undertaking risk assessments and putting in place appropriate mitigation to safeguard data and having good governance/audit arrangements to prevent contraventions of data protection regulations. The ICO may also prosecute those who commit criminal offences under data protection legislation. These guides take you through the definitions used in the standards, what the standards are asking of you, suggestions and examples of how this might be achieved, how this relates to common current practices, and useful resources. The DSP toolkit (also known as the data security and protection toolkit) is an online self assessment tool that enables organisations to measure and publish their performance against the National Data Guardian’s ten data security standards.You can access the toolkit … A. Whilst there is not a specific requirement in data protection legislation to encrypt computers containing personal information, contractors must ensure that personal information is adequately protected. The guidance for this requirement states, “Patient identifiable information stored on a PC hard drive or other removable device in a non-secure area or on a portable device such as a laptop, PDA or mobile phone should be encrypted. The Online Toolkit Join our mailing list for a weekly round-up of news and resources, plus price concession/NCSO alerts. A. This requirement relates to safeguarding mobile devices that are used to store personal information. Health and care organisations are encouraged to conduct staff awareness surveys to gauge staff understanding of data security. The DSP Toolkit … Police officers or other persons authorised by the Secretary of State who are engaged to routinely check CD registers and officers monitoring the prescribing of CDs may demand production of and to inspect any books or documents relating to CDs – this includes the CD register and any prescriptions that have been retained on the premises. Alternatively if it is a significant error and the Helpdesk is unable to provide support, contact your local NHS England team. The Data Security and Protection Toolkit is an online self-assessment tool that allows organisations to measure their performance against the National Data Guardian’s 10 security standards. Q. While the impact of a burglary of either pharmacy will be the same – the actual probability of the burglary taking place will be quite different – and therefore the security measures at each will differ. A. The commonly used term “named patient supply” is incorrect in that the term used in the legislation is “individual patients” and although there must be an audit trail which ultimately leads to an individual patient, there is no need for those involved in the supply chain to know the name of that patient. Data Security and Protection Toolkit in a spreadsheet for Category 1 NHS Trusts, Category 2 ALBs, CCGs and CSUs, Category 3 Others and Category 4 GPs. It is now possible for a Head Office staff member to centrally view the submissions of individual stores through a central log-in. 9 Guidance for Care Providers for the Data Security and Protection Toolkit Final version of this guidance willinclude: • ‘Tool tips’ guidance to accompany the assertions in the newtoolkit • An updated Guide for Registered Managers • An updated Guide for Staff • ‘Big Picture’Guides (overall view of 10 Data … Two identical pharmacies holding the same information, computers and stock may have quite different physical security needs if one is located in an area of high crime and the other in a low crime area. In the pharmacy’s records, it would be acceptable to document a position, for example, ‘the pharmacy manager’ or ‘Clinical Governance Lead’ rather than a named individual, as long as the staff member(s) concerned are clear from this that they are responsible and it is clear to other staff who the IG Lead is. Is this correct? Please ensure your email address is correct. Q. A. All organisations that have access to NHS patient data and systems must use the toolkit to provide assurances that they are practising good data security and that personal data is handled correctly. Before disclosing patient data, pharmacists would need to satisfy themselves that the person requesting the data is properly authorised under the Misuse of Drugs Act and that the request for information is consistent with the carrying out of routine checks. A detailed briefing on the legal and ethical provisions that limit or prohibit the use of personal information can be found in the NHS Information Governance: Pharmacy Contractor workbook. No technical knowledge is needed. It is the responsibility of the NHS England Area team to organise the disposal of waste. ... Data Security and Protection Toolkit … Data Security and Protection Toolkit staff awareness questions, 7. User-friendly, this guide makes completing the updated Toolkit … The Information Commissioner’s Office (ICO) enforces and oversees data protection legislation. To date £12m has been allowed. There is a greater risk of laptops etc being stolen even if they are not removed from the pharmacy, therefore the appropriate measures as outlined in the requirements must be taken. This list of questions can be used in local training materials or incorporated into local e-learning solutions. But there may be differences depending on the nature of services provided under the LPS, therefore we recommend discussing this with your local NHS England team. Find out about locally commissioned community pharmacy services. It is for a contractor to assess the risk they face based on local circumstances. Further information to support NHS Trusts, CCGs, CSUs and DHSC ALBs to complete evidence item 1.4.1. Data Security, IG and Toolkit frequently asked questions. 14 Hosier Lane In practice, this means achieving the required level with the nationally specified NHS Information Governance requirements, and making an annual declaration via the Information Governance Toolkit. PSNC is currently in discussion with the DHSC to finalise the funding allocation for business continuity planning. The Data Security and Protection Toolkit uses cookies to improve your on-site experience. It is exceptionally burdensome for pharmacies and there is a risk that patient identifiable information will be inadvertently disclosed. An alternative to the patient’s name could be using the patient’s PMR record number which can be traced back to the patient by the pharmacy or alternatively a unique identification number provided by the manufacturer that the pharmacy can record on the patient’s PMR record for future reference. A. A number of changes were made to the Terms of Service requirements (Clinical Governance) in October 2011 to require pharmacies to comply with an approved information governance programme. There are a number of exceptional circumstances in which personal data can be disclosed without patient consent, for example, where disclosure of personal data is necessary to prevent serious injury or damage to the health of a patient. Q. I have heard that I need to encrypt my computers to reach level 2 of the NHS Information Governance Toolkit. This page provides an overview of the Data Security and Protection Toolkit. For example if a contractor owns multiple pharmacies, he may feel it appropriate to appoint one central lead with local leads in each store to provide information on local circumstances and support pharmacy implementation of the requirements. There is also a workbook which was created to support care providers completing the Data Security and Protection Toolkit as … This portal provides links to websites for all Local Pharmaceutical Committees (LPCs). Q. I’m currently in the process of data mapping and risk assessing all flows of personal information. Q. I have received an FP10 prescription for an unlicensed “named patient supply” product. When serving monetary penalties, the Information Commissioner will carefully consider the circumstances, including the seriousness of the data breach; the likelihood of substantial damage and distress to individuals; whether the breach was deliberate or negligent and what reasonable steps the organisation has taken to prevent breaches. Occasionally a pharmacy may be visited by a police officer who is undertaking an investigation into an alleged serious criminal offence (i.e. The Data Security Meta Standard provides more information on what the ten data security standards are and why they are important. Pharmacies should use their judgement based on local circumstances on which pieces of hardware should be recorded on the asset register. A. The level of risk is normally established by considering the impact of a data loss and the likelihood of that loss taking place. Is it still regarded as ‘mobile computing’? This page includes guidance carried over from the predecessor system, the 'Information Governance Toolkit'. FAQs about Data and Security Protection (IG) Toolkit and data security can be found below. In another area, if there have been problems with hand-delivering prescriptions to the surgery, for example problems with the GP surgery reporting they didn’t receive the forms, this would be a higher risk and the pharmacy would have to consider options to mitigate the risk. £90 million of investment was agreed for these unavoidable one-off infrastructure costs. However the pharmacy may still find benefits in doing this for other reasons, for example to minimise the risk of theft. Do I need to complete 2 submissions? Some of the NHS IG requirements therefore have a specific focus on either digital or hardcopy information. Historic Data Security and Protection Toolkit … Report product over Drug Tariff price A. The intention of including ‘asset number’ in the template register was to provide a reference to link between the register and the asset itself for tracking purposes. Q. I have both an LPS Contract and a General Pharmaceutical Services contract. If you have a support query, please contact us at https://www.dsptoolkit.nhs.uk/Home/Contact. Will funding be available in future years to reflect the ongoing costs in continuing to comply with the requirements? Powers are granted under the Misuse of Drugs Act 1971 to carry out these routine checks .  The persons described above may take copies of documents or in some cases remove from the pharmacy premises original documents as part of their CD responsibilities under the Misuse of Drugs Act.  Disclosure in these cases is specifically authorised by the law, and this overrides the duty to protect patient confidentiality. A. A. Therefore, before faxing a prescription to a manufacturer, any information that could be used to identify the patient must be obscured / redacted in black ink unless the patient has consented to their personal data being disclosed. This page provides an overview of the Data Security and Protection Toolkit and its core functionality. Data breaches are all over the news, and organizations are acutely aware that even if they have achieved PCI compliance or SOX compliance, new compliance regulations like the GDPR demand more stringent data security controls.To help you improve your security and compliance posture, we have put together a list of the top 12 data security solutions for protecting sensitive data … Further to detailed negotiations on the work involved, the DHSC and PSNC agreed that over £23 million of this sum was to support the implementation of the IGT, which equates to over £2000 per pharmacy. The pharmacy must be able to show that the role has been appropriately assigned. A. The template SOPs have been developed by PSNC and the RPSGB with support from the DHSC, NHS Connecting for Health and NHS Employers. Strengthening Assurance - Independent Assessment Guides 20-21, 6. Q. I use a mobile device for connecting to the internet for drug information but it does not hold any patient sensitive information. The 2010/11 community pharmacy contractual framework funding settlement included provision for the costs of PC renewal in community pharmacies. Queries on specific IG requirements can be found towards the bottom of the page. About the Data Security and Protection Toolkit, 3.1. It is recognised however that this may take some time to achieve. Of these the PSNC have highlighted 15 as technical questions … Can I correct the answers after clicking the submit button? not routinely exercising powers under the Misuse of Drugs Act 1971).  As this may not be the police officer who normally visits to inspect the registers, pharmacy contractors will wish to verify the identity of the police officer, and receive confirmation that the police officer is investigating a possible serious offence. prescription forms as well as information held electronically? A. A number of manufacturers are requesting that contractors fax anonymised copies of prescriptions before stock is released. If the device has patient information on it, it must be protected. On the 1st April 2013, responsibility for monitoring and supporting pharmacy information governance passed from PCTs to NHS England Area teams (now local NHS England teams). How to find us For a multiple pharmacy, when registering for access to the IG Toolkit, is it possible to register using the same name and log-in email for each premises and just change the ODS code? Guidance on reporting an incident for GDPR and NIS. checking with your PMR supplier that any personal data transmitted electronically remains in the UK). Users can also change their password. Where is the funding for pharmacies initially implementing the IG requirements coming from? Do I need to declare this in my Information Asset Register? Q. Briefings published by PSNC covering topics such as opening hours, regulations, and NHS IT matters. NHS Digital’s Data Security and Protection Toolkit (DSPT) is a free, online self-assessment of your compliance with:. Pharmacies should ensure that their action plan is filed locally so that it is available to show to local NHS England team officials during support visits (which may be part of contractor monitoring visits) to the pharmacy. A locum may be able to fulfil this role, but this will be for local decision.   Data security standards - big picture guides, 6.1. Return to the section: Data security and information governance, Return to the section: Data Security and Protection Toolkit, Return to the Pharmacy IT hub or IT a-z index. Q. Similar requirements on the disclosure of personal data exist under the common law duty of confidentiality. Although the laptop does not contain patient information, it still may pose risks to information held on the local network and therefore actions may still need to be taken to manage any risks. e-Learning – data security awareness – level one (v3.0), 3. Do I need to invest in e.g. A. Yes, in 2015 the requirement came in which meant that pharmacies are no longer exempt from having a business continuity plan in place. More information about ‘privacy notices’ can be found on the Information Commissioner’s website. Are the template SOPs good enough to comply with the NHS Requirements? What will this be used for? The manufacturer is requesting that I share the prescription form serial number. Information Governance ensures necessary safeguards for, and appropriate use of, patient and personal information. A. Q. Pharmacies have a duty to protect the confidentiality of patient’s sensitive data.  How is this duty reconciled when a police officer asks to discuss the prescribing of CDs for patients. Are pharmacies required to have a business continuity plan? 6.4. Q. I have already submitted my baseline IG Assessment. Any improvements in the scores should be entered into the next version of the Information Governance Toolkit. My system supplier doesn’t store data outside of the UK but provides remote assistance from outside of the UK, how do I make sure I comply with data protection legislation and DHSC guidelines? Q. Q. I can’t obtain a common branded product from my wholesaler. If so, only the minimum amount of personal data necessary should be disclosed. The pharmacy will need to give consideration to how pharmacies can access the leaflet, for example sent regularly to all patients, sent once to all patients and then to new patients who use the service or made available on the website with a pointer to it. It was identified for a number of one-off costs pharmacy contractors are facing, including information governance. 6. Further guidance on the powers of authorised persons under the Misuse of Drugs legislation may be available from the Home Office, the Association of Police Controlled Drugs Liaison Officers, the General Pharmaceutical Council, the NPA (for members) and from the RPS (for members). The Information Commissioner has formed the view that in future, where such losses occur and where encryption software has not been used to protect the data, regulatory action may be pursued. Do I need to have a confidentiality clause in the contracts of third party contractors who don’t have access to patient identifiable information? 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